Washington, D.C. – The Class Counsel under the Reggie White settlement agreement and the NFL Players Association today filed a complaint, on behalf of the NFL players, charging the NFL, its clubs and their owners of collusion during the 2010 NFL season. The complaint details a conspiracy to violate the anti-collusion and anti-circumvention provisions in the White Settlement Agreement (SSA) by “imposing a secret $123 million per-Club salary cap for that uncapped 2010 season.”

The written claim is filed with the United States District Court of Minnesota, which oversees the SSA and alleges that the league and owners acted illegally and “solely by self-interest, unconstrained by their clear and unambiguous SSA obligations.”

“When the rules are broken in a way that hurts the game, we have an obligation to act. We cannot standby when we now know that the owners conspired to collude,” said DeMaurice Smith, NFLPA Executive Director.

“Our union recently learned that there was a secret salary cap agreement in an uncapped year. The complaint today is our effort to fulfill our duty to every NFL player. They deserve to know, above all, the facts and the truth about this conspiracy,” said Domonique Foxworth, NFLPA President.

The complaint cites John Mara, owner of the New York Giants, who also serves as the Chair of the NFL Management Council Executive Committee, as publicly confirming that the NFL directed teams to restrict players’ salaries during the uncapped year. When asked about imposed penalties for the Redskins and Cowboys, he replied: “What they did was in violation of the spirit of the salary cap. They attempted to take advantage of a one-year loophole … full well knowing there would be consequences.”

Such a scheme breaches express anti-collusion and anti-circumvention provisions of the SSA and the owners’ duty of good faith in implementing the SSA.

In the filing, it is alleged that the NFL and owners furthered their concealment by “approving the very player contracts that enabled the Redskins, Cowboys, Raiders, and Saints to exceed the secret, collusive salary cap” and, prior to and on March 11, 2012, failed to disclose to the players or the NFLPA “that the true reason for the then-proposed reallocation was to penalize the Redskins, Cowboys, Raiders, and Saints for not fully abiding by the Collusive Agreement.”

Also as described in the complaint, these collusion and other claims are entirely new and were previously unknown to the players and the NFLPA. They therefore were not asserted, and could not have been asserted, in the previous actions that were filed in either Brady. v. NFL or under the SSA in the White litigation.

The players and the NFLPA will be represented in these proceedings by Jeffrey Kessler, David Feher and David Greenspan of Winston & Strawn, LLP; James Quinn of Weil, Gotshal & Manges, LLP; David Barrett, James Barrett, Daniel Schecter, Thomas Heiden and Michael Nelson of Latham & Watkins, LLP; Barbara Berens of Berens & Miller, P.A.; Mark Jacobson of Lindquist & Vennum, PLLP and DeMaurice Smith, Executive Director of the NFLPA.